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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The origin and objectives of CRS and Automatic Exchange of Information (AEOI)
  • Identification of Reporting Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, highlighting overlaps and distinct requirements

Legal & Regulatory Landscape

  • Jurisdictional implementation models and associated legal instruments (e.g., MCAA, domestic laws)
  • Recent consolidated texts and amendments affecting due diligence scope
  • Compliance duties, deadlines, and consequences of non-adherence

Due Diligence Essentials: Determining Tax Residency

  • Necessary documentation, including self-certifications and reliable supporting evidence
  • Indicia search protocols for both new and existing accounts
  • Broader due diligence approaches and leveraging AML/KYC data to verify tax residence

Operationalizing CRS: Onboarding, Data Collection, and Systems

  • Incorporating CRS checks into client onboarding and periodic review cycles
  • Essential data elements for reporting, with a focus on data quality and retention strategies
  • Evaluating automation and vendor tools against manual processes, particularly for service providers

FATCA-like Requirements and Comparative Best Practices

  • Shared aspects with FATCA, such as classification, reporting mechanics, and entity treatment
  • Key differences to consider, including scope and the distinction between bilateral and multilateral implementations
  • Practical mapping exercises to translate FATCA controls into CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Preparedness

  • CRS report formats, transmission methods, and jurisdictional submission mandates
  • Preparing for audits and regulatory reviews through proper documentation, traceability, and due diligence evidence
  • Illustrative reporting workflows and reconciliation checks

Risk Management, Governance, and Internal Controls

  • Building governance frameworks, policies, and segregation of duties for CRS compliance
  • Training, quality assurance, and exception management for complex and entity accounts
  • Remediation strategies and multi-jurisdiction coordination for legacy accounts

Practical Labs and Case Studies

  • Lab: Assess and verify sample account files and self-certifications to determine reportability
  • Lab: Set up a basic data-extraction and reporting checklist to generate a mock CRS XML extract
  • Case study: Managing complex entity structures, trusts, and controlling persons under CRS rules

Conclusion and Future Steps

Requirements

  • Fundamental understanding of financial services or compliance operations
  • Knowledge of basic tax principles and client onboarding procedures
  • Prior experience with AML/KYC processes is advantageous but not mandatory

Target Audience

  • Compliance officers and legal department members
  • Staff responsible for onboarding, KYC, and client due diligence
  • Tax reporting and operations teams within financial institutions

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